2026 (6) TMI 999

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....marnath Reddy Counsel for the Respondent : Special Govt Pleader for State Tax ORDER: Heard Mr. K.P. Amarnath Reddy, learned counsel for the petitioner and Mr. Swaroop Oorilla, learned Government Pleader for State Tax appearing for the respondents. 2. The instant is the writ petition which has been filed challenging the order passed by the Appellate Joint Commissioner of State Tax, date....

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.... is within the period of three months from 24.11.2025. In the appeal, the petitioner had challenged the original order dated 29.08.2024 and not rectification order dated 24.11.2025. On account of which, the Appellate authority had rejected the appeal on the ground of it being barred by limitation counting the limitation from the date original order was passed on 29.08.2024. 3. The contention of....

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....out explanation on 19.02.2026. 4. Per contra, the learned Special Government Pleader, appearing for the respondents, opposing the petition submits that the petitioner since has preferred an appeal after rejection of the rectification application. For all practical purposes, the petitioner ought to have challenged the rectification order itself in the appeal, which is otherwise permissible under....

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....been genuinely pursuing her remedies available under the statute against the original order dated 29.08.2024 and only after her rectification application stood rejected, she has again timely filed the appeal within the period of three months from the date when the rectification application stood rejected. 7. In view of the same, we are of the considered opinion that the Appellate Commissioner o....